1. Introduction

1.1. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.2. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.3. In this policy, "we", "us" and "our" refer to Judd & Judd Ltd. For more information about us, see Section 15.

2. How we use your personal data

2.1. In this Section 2 we have set out:

the general categories of personal data that we may process;

in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

the purposes for which we may process personal data; and

the legal bases of the processing.

2.2. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3. We may process information and content that you submit for publication, or otherwise agree to publish, on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4. We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests.

2.5. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, including your specified delivery address, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services, invoicing and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.6. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.7. We may process any of your personal data
for the purposes of auditing and record-keeping ("record-keeping data"). This data may include your name,
business email address, company and job title. The source of this data is our
correspondence with you. This data may be processed for the purposes of
maintaining contacts, including for the purposes of datacleansing content published on our
website, or for contacting you regarding your interest in advertising with us, or for advert renewals, and enquiries. The legal basis for this
processing is our legitimate interests, namely the proper administration of our
website and business.

2.8. We may process any of your personal data
for the purposes of conducting surveys (“survey
data”). This data may include your name, business email address, company
and job title, together with any comments you submit. This data may be processed
for the purposes of analysing survey responses for publication on our website.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business.

2.9. We may process any of your personal data identified in this
policy where necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is our legitimate interests,
namely the protection and assertion of our legal rights, your legal rights and
the legal rights of others.

2.10. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12. Please do not supply any other person's
personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1. We may disclose your personal data to any member of our group of companies (Judd & Judd Ltd, and our trading companies Judd Water and Wastewater Consultants and The MBR Site) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3. We may disclose personal data as set out in Section 2 to the following suppliers and/or subcontractors identified below insofar as reasonably necessary for the proper administration of our website and business and communications with users:

3.4. Financial transactions relating to our website and services are handled by our payment services providers, PayPal and HSBC bank. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:

3.5. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1. In this Section 4, we provide
information about the circumstances in which your personal data may be
transferred to countries outside the European Economic Area (EEA).

4.2. We (including our trading companies) have offices and facilities in the United Kingdom. However, we operate our website and business services worldwide. We may use:

4.3. The hosting facilities for our website are situated in the United Kingdom.

4.4. You acknowledge that personal data that you submit for
publication through our website or services may be available, via the internet,
around the world. We cannot prevent the use (or misuse) of such personal data
by others.

5. Retaining and deleting personal data

5.1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3. We will retain your personal data as follows:

Usage data will be retained for a minimum period of 26 months following each use of our website and services, and for a maximum period of 38 months following use.

Publication data will be retained for the entire period of publication on our website, and for a minimum period of 12 months following deletion of publication data from our website and for a maximum period of 24 months following deletion.

Enquiry data will be retained for a minimum period of 12 months following the initial enquiry (if no subsequent correspondence received) and for a maximum period of 24 months following this initial enquiry (if no subsequent correspondence received).

Transaction data will be retained for a minimum period of 7 years following the transaction date and for a maximum period of 8 years following the transaction date. This is for accounting purposes.

Correspondence data will be retained for a minimum period of 1 year following the date of the last contact, and for a maximum period of 2 years following the date of the last contact.

Record-keeping data will be retained for the entire period of the publication of related content on our website, and for a minimum period of 12 months following deletion of publication data from our website and for a maximum period of 24 months following deletion.

Survey data will be retained for the entire period of the publication of related content on our website, and for a minimum period of 12 months following deletion of publication data from our website and for a maximum period of 24 months following deletion.

5.4. In some cases it is not possible for us to specify in advance
the periods for which your personal data will be retained. In such cases, we
will keep your data for no longer than is necessary.

5.5. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Security of personal data

6.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

6.3. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7. Amendments

7.1. We may update this policy from time to time by publishing a new version on our website.

7.2. You should check this page occasionally to ensure you are happy with any changes to this policy.

8. Your rights

8.1. In this Section 8, we have summarised
the rights that you have under data protection law. Some of the rights are
complex, and not all of the details have been included in our summaries.
Accordingly, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.

8.2. Your principal rights under data protection law are:

the right to access;

the right to rectification;

the right to erasure;

the right to restrict processing;

the right to object to processing;

the right to data portability;

the right to complain to a supervisory authority; and

the right to withdraw consent.

8.3. You have the right to confirmation as to whether or not we
process your personal data and, where we do, access to the personal data,
together with certain additional information. That additional information
includes details of the purposes of the processing, the categories of personal
data concerned and the recipients of the personal data. Providing the rights
and freedoms of others are not affected, we will supply to you a copy of your
personal data. The first copy will be provided free of charge, but additional
copies may be subject to a reasonable fee.

8.4. You can request access to your personal data by emailing info@thembrsite.com in the first
instance. We will require proof of your identity before processing any request.
You will be required to prove your identity by sending us a copy of your
passport ID page, certified by a solicitor or your bank, plus a utility bill
showing your home address and dated in the last three months.

8.5. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.6. In some circumstances you have the right to the erasure of your
personal data without undue delay. Those circumstances include: the personal
data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed; you withdraw consent to consent-based
processing; you object to the processing under certain rules of applicable data
protection law; the processing is for direct marketing purposes; and the
personal data have been unlawfully processed. However, there are exclusions of
the right to erasure. The general exclusions include where processing is
necessary: for exercising the right of freedom of expression and information;
for compliance with a legal obligation; or for the establishment, exercise or
defence of legal claims.

8.7. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.8. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.9. You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.

8.10. To the extent that the legal basis for
our processing of your personal data is:

consent;
or

that
the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a
contract,

and
such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would adversely
affect the rights and freedoms of others.

8.11. If you consider that our processing of
your personal information infringes data protection laws, you have a legal
right to lodge a complaint with a supervisory authority responsible for data
protection. You may do so in the EU member state of your habitual residence,
your place of work or the place of the alleged infringement.

8.12. To the extent that the legal basis for
our processing of your personal information is consent, you have the right to
withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.

8.13. You may exercise any of your rights in relation to your personal
data by emailing info@thembrsite.com in the first
instance. We will require proof of your identity before processing any request.
You will be required to prove your identity by sending us a copy of your
passport ID page, certified by a solicitor or your bank, plus a utility bill
showing your home address and dated in the last three months.

9. Third party websites

9.1. Our website includes hyperlinks to, and details of, third party websites.

9.2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Updating information

10.1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. About cookies

11.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

12. Cookies that we use

12.1. We use cookies for the following purposes:

analysis − we use cookies to help us to analyse the use and performance of our website and services

social media − when you watch embedded YouTube videos

functionality of our contact and enquiry forms

cookie consent − we use cookies to store your preferences in relation to the use of cookies more generally.

13. Cookies used by our service providers

13.1. Our service providers use cookies and
those cookies may be stored on your computer when you visit our website.

13.2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.

13.6. We use SurveyMonkey to collect individual responses when conducting our surveys. This service uses third-party cookies for tracking and analysing the use of their service, and for targeting advertising.

14. Managing cookies

14.1. Most browsers allow you to refuse to
accept cookies and to delete cookies. The methods for doing so vary from
browser to browser, and from version to version. You can however obtain
up-to-date information about blocking and deleting cookies via these links:

16. Data protection registration

16.1. We are registered as a data controller with the UK Information Commissioner's Office.

16.2. Our data protection registration reference is ZA345894.

17. Representative within the European Union

17.1. Our representative within the European Union with respect to our obligations under data protection law is the Information Commissioner’s Office (ICO) in the United Kingdom and you can contact our representative by visiting:
https://ico.org.uk/global/contact-us/